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 June 27, 2025

Chirag Bhavsar
Chief Executive Officer
CNL Strategic Residential Credit, Inc.
450 South Orange Avenue, Suite 1400
Orlando, Florida 32801-3358

 Re: CNL Strategic Residential Credit, Inc.
 Form 10-12G
 Filed on June 2, 2025
 File No. 000-56755
Dear Chirag Bhavsar:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response and any amendment you may file in
response to this
letter, we may have additional comments.

Form 10-12G filed on June 2, 2025
Share Repurchase Plan, page 27

1. We note your disclosure on pages 27-28 and 125 that you will use
periodic NAV
 pricing for both your offerings and share repurchase plan. Please
clarify both
 discussions how you will communicate the prior period s NAV for the
various classes
 of shares. Further, in the event of adjustments to the offering price
prior to acceptance
 of subscriptions, please clarify how investors can check for an adjusted
offering price
 prior to the closing date of their subscription.
2. Please be advised that you are responsible for analyzing the
applicability of the tender
 offer rules, including Rule 13e-4 and Regulation 14E, to your share
repurchase plan.
 We urge you to consider all the elements of your share repurchase plan
in determining
 whether the program is consistent with relief granted by the Division of
Corporation
 Finance in prior no action letters. To the extent you are relying on
Blackstone Real
 Estate Income Trust, Inc. (Letter dated September 12, 2016), Rich Uncles
NNN REIT,
 Inc. (Letter dated December 21, 2016), Hines Global REIT II, Inc.
(Letter dated April
 June 27, 2025
Page 2

 26, 2017), or Black Creek Diversified Property Fund Inc. (Letter dated
September 1,
 2017), please provide us with an analysis as to how your program is
consistent with
 such relief. To the extent you have questions as to whether the program
is entirely
 consistent with the relief previously granted by the Division of
Corporation Finance,
 you may contact the Division s Office of Mergers and Acquisitions at
202-551-3440.
3. Please be advised that you are responsible for analyzing the
applicability of
 Regulation M to your share repurchase plan. We urge you to consider all
the elements
 of your share repurchase plan in determining whether the program is
consistent with
 the class relief granted by the Division of Market Regulation in the
class exemptive
 letter granted Alston & Bird LLP dated October 22, 2007. To the extent
you have
 questions as to whether the plan is entirely consistent with that class
exemption, you
 may contact the Division of Trading and Markets at 202-551-5777.
Risk Factors, page 57

4. Please add risk factor disclosure highlighting the risk that in certain
circumstances,
 you can exceed the limitation in your charter on borrowing in excess of
300% of the
 value of your net assets, as noted on page 13.
Security Ownership of Certain Beneficial Owners and Management, page 107

5. Please identify the natural person or persons who, directly or
indirectly, exercise sole
 or shared voting and/or investment powers with respect to the shares
held by CNL
 Residential Credit Manager, LLC and Balbec Capital Holdings, L.P.
Notes on Financial Statements
6. Subsequent Events, page F-5

6. We note you have reviewed subsequent events through May 15, 2025, which
precedes
 the date of the report from your independent registered public
accounting firm. Please
 tell us what consideration you gave to evaluating subsequent events
through the audit
 report date noted. Refer to ASC 855-10-25.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Babette Cooper at 202-551-3396 or Mark Rakip at
202-551-3573 if
you have questions regarding comments on the financial statements and related
matters. Please contact David Link at 202-551-3356 or Mary Beth Breslin at
202-551-3625
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Jason Myers
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